The transfer pricing environment is undergoing significant change. At the request of the G20, the OECD has led a programme to discuss base erosion and profit shifting (“BEPS”) which has included a review of its transfer pricing guidance. Going forward, multinational groups will be required to provide greater transparency of their operations and tax profile in the countries where they operate and greater scrutiny of the tax affairs of multinational groups is to be expected.
Our Transfer Pricing Team
The FTI Consulting Transfer Pricing team draws on the unparalleled experience of over 120 economists who price complex commercial and financial transactions, undertake valuations of intangibles and stand as expert witnesses in litigation cases.
Our Transfer Pricing team is fully engaged with the BEPS programme and is actively participating in the OECD’s consultations on transfer pricing matters, including Cost Contribution Arrangements and Hard-to-Value Intangibles. Also the team advises on the post BEPS environment and providing practical solutions to ensure adherence to new OECD guidance.
We provide a fully integrated transfer pricing service supported by our deep international tax and economic expertise. In addition, we are part of an international tax network of highly respected transfer pricing and international tax professionals for the delivery of multi-jurisdiction projects.
As FTI Consulting is free from audit and assurance client relationships, our clients can be certain that we will always be positioned to defend their transfer pricing policies and advise them on an ongoing basis.
- Advising on transfer pricing strategy which aligns tax compliance and business objectives
- BEPS impact analysis and advising clients on solutions compliant with the latest OECD recommendations
- Preparation of master file (global/local) documentation, including reviewing country-by-country reports and performing risk analysis
- Managing disputes with tax authorities
- Restructuring and/or acquisition advisory
- Advance Thin Capitalisation Agreements (“ACTAs”) and Advance Pricing Agreements (“APAs”)
- Pricing complex intra-group financial arrangements
- Valuing intangible assets, for licensing or sale purposes
- Optimising the tax efficiency of supply chains
- Undertaking Diverted Tax Profits (“DPT”) risk reviews and mitigating DTP risk